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Mr. G. Russell Means <br />August 28, 2017 <br />Page 2 <br />permit with DRMS and the Iease with DOE." The Board's order, dated May 7, 2013, covering <br />the SR -13A Mine and other mines is to the same effect: "Valuable mineral reserves remain in <br />each of the Mines." Order, dated May 7, 2013, at 7, 1 57. Cotter intends to mine the SR -13A <br />Mine's reserves when market conditions recover, and has submitted a plan to the Division for <br />doing so. See Cotter's I l Od Application Amendment ("Application Amendment") for the SR - <br />13A Mine, Exh. C. The Division has also approved Cotter's Environmental Protection Plan <br />("EPP") Amendment for the SR -13A Mine, as explained in the Division's letter to Cotter dated <br />August 19, 2013. The life of the SR -13A Mine is projected to be between ten and fifteen years. <br />Application Amendment, Exh. C. For these reasons, Cotter's reclamation permit should not be <br />terminated, and the SR -13A site should not be inspected for final release. <br />Although the SR -13A Mine retains substantial economic reserves, and Cotter plans to mine those <br />reserves, a second five-year period of temporary cessation for the SR -13A Mine is appropriate. <br />As indicated above, production at the SR -13A Mine has been suspended due to adverse uranium <br />market conditions. The mining operation also could not, and cannot now, recommence due to <br />the injunction ordered by the United States District Court for the District of Colorado in <br />Colorado Environmental Coalition v. Office of Legacy Management, 819 F. Supp. 2d 1193, <br />1224-225 (D. Colo. 2011). Although the District Court subsequently amended its injunction to <br />exclude from the injunction's scope certain maintenance and reclamation activities and other <br />work, it did not exclude from the injunction and, accordingly, still does not authorize <br />"exploration, drilling [and] mining" on Uranium Lease Management Program lands. Colorado <br />Environmental Coalition v. Office of Legacy Management, 2012 WL 628547 (D. Colo. Feb. 27, <br />2012). The District Court recently confirmed that the injunction remains in effect. Colorado <br />Environmental Coalition v. Office of Legacy Management, No. 08-cv-1624-WJM-MJW, Order <br />Denying Plaintiffs' Motion to Supplement (March 7, 2017) (ECF 146), at 3 ("That injunction <br />remains in effect ...."). <br />Interim surveillance and maintenance will be conducted to keep the associated stormwater <br />management controls working effectively as described in the SR -13A Mine's EPP, attached as <br />Exhibit T to Cotter's Application Amendment. The EPP and Application Amendment also <br />contain the measures to be taken to comply with reclamation requirements and/or other activities <br />related to the performance standards of Section 3.1 of the Hard Rock/Metal Mining Rules, which <br />will continue to be implemented during periods of temporary cessation and are incorporated by <br />reference into this letter. <br />The existing financial warranty of [$27,700] held by the Division and the United States <br />Department of Energy is adequate to cover the reclamation liability of the SR -13A Mine. See <br />letter, dated August 19, 2013, from the Division to Cotter ("[F]inancial warranty shall be set at <br />1831715 1 <br />